US20020055566A1 - Water-based formulations with fungicidal action - Google Patents

Water-based formulations with fungicidal action Download PDF

Info

Publication number
US20020055566A1
US20020055566A1 US09/552,044 US55204400A US2002055566A1 US 20020055566 A1 US20020055566 A1 US 20020055566A1 US 55204400 A US55204400 A US 55204400A US 2002055566 A1 US2002055566 A1 US 2002055566A1
Authority
US
United States
Prior art keywords
aqueous systems
binders
hydrolysis
water
active compounds
Prior art date
Legal status (The legal status is an assumption and is not a legal conclusion. Google has not performed a legal analysis and makes no representation as to the accuracy of the status listed.)
Abandoned
Application number
US09/552,044
Inventor
Hans-Ulrich Buschhaus
Peter Spetmann
Thomas Jaetsch
Martin Kugler
Current Assignee (The listed assignees may be inaccurate. Google has not performed a legal analysis and makes no representation or warranty as to the accuracy of the list.)
Lanxess Deutschland GmbH
Original Assignee
Individual
Priority date (The priority date is an assumption and is not a legal conclusion. Google has not performed a legal analysis and makes no representation as to the accuracy of the date listed.)
Filing date
Publication date
Application filed by Individual filed Critical Individual
Assigned to BAYER AKTIENGESELLSCHAFT reassignment BAYER AKTIENGESELLSCHAFT ASSIGNMENT OF ASSIGNORS INTEREST (SEE DOCUMENT FOR DETAILS). Assignors: JAETSCH, THOMAS, KUGLER, MARTIN, SPETMANN, PETER, BUSCHHAUS, HANS-ULRICH
Publication of US20020055566A1 publication Critical patent/US20020055566A1/en
Assigned to LANXESS DEUTSCHLAND GMBH reassignment LANXESS DEUTSCHLAND GMBH ASSIGNMENT OF ASSIGNORS INTEREST (SEE DOCUMENT FOR DETAILS). Assignors: BAYER AG
Abandoned legal-status Critical Current

Links

Classifications

    • AHUMAN NECESSITIES
    • A01AGRICULTURE; FORESTRY; ANIMAL HUSBANDRY; HUNTING; TRAPPING; FISHING
    • A01NPRESERVATION OF BODIES OF HUMANS OR ANIMALS OR PLANTS OR PARTS THEREOF; BIOCIDES, e.g. AS DISINFECTANTS, AS PESTICIDES OR AS HERBICIDES; PEST REPELLANTS OR ATTRACTANTS; PLANT GROWTH REGULATORS
    • A01N27/00Biocides, pest repellants or attractants, or plant growth regulators containing hydrocarbons
    • AHUMAN NECESSITIES
    • A01AGRICULTURE; FORESTRY; ANIMAL HUSBANDRY; HUNTING; TRAPPING; FISHING
    • A01NPRESERVATION OF BODIES OF HUMANS OR ANIMALS OR PLANTS OR PARTS THEREOF; BIOCIDES, e.g. AS DISINFECTANTS, AS PESTICIDES OR AS HERBICIDES; PEST REPELLANTS OR ATTRACTANTS; PLANT GROWTH REGULATORS
    • A01N47/00Biocides, pest repellants or attractants, or plant growth regulators containing organic compounds containing a carbon atom not being member of a ring and having no bond to a carbon or hydrogen atom, e.g. derivatives of carbonic acid
    • A01N47/02Biocides, pest repellants or attractants, or plant growth regulators containing organic compounds containing a carbon atom not being member of a ring and having no bond to a carbon or hydrogen atom, e.g. derivatives of carbonic acid the carbon atom having no bond to a nitrogen atom
    • A01N47/04Biocides, pest repellants or attractants, or plant growth regulators containing organic compounds containing a carbon atom not being member of a ring and having no bond to a carbon or hydrogen atom, e.g. derivatives of carbonic acid the carbon atom having no bond to a nitrogen atom containing >N—S—C≡(Hal)3 groups
    • AHUMAN NECESSITIES
    • A01AGRICULTURE; FORESTRY; ANIMAL HUSBANDRY; HUNTING; TRAPPING; FISHING
    • A01NPRESERVATION OF BODIES OF HUMANS OR ANIMALS OR PLANTS OR PARTS THEREOF; BIOCIDES, e.g. AS DISINFECTANTS, AS PESTICIDES OR AS HERBICIDES; PEST REPELLANTS OR ATTRACTANTS; PLANT GROWTH REGULATORS
    • A01N25/00Biocides, pest repellants or attractants, or plant growth regulators, characterised by their forms, or by their non-active ingredients or by their methods of application, e.g. seed treatment or sequential application; Substances for reducing the noxious effect of the active ingredients to organisms other than pests
    • A01N25/22Biocides, pest repellants or attractants, or plant growth regulators, characterised by their forms, or by their non-active ingredients or by their methods of application, e.g. seed treatment or sequential application; Substances for reducing the noxious effect of the active ingredients to organisms other than pests containing ingredients stabilising the active ingredients
    • CCHEMISTRY; METALLURGY
    • C09DYES; PAINTS; POLISHES; NATURAL RESINS; ADHESIVES; COMPOSITIONS NOT OTHERWISE PROVIDED FOR; APPLICATIONS OF MATERIALS NOT OTHERWISE PROVIDED FOR
    • C09DCOATING COMPOSITIONS, e.g. PAINTS, VARNISHES OR LACQUERS; FILLING PASTES; CHEMICAL PAINT OR INK REMOVERS; INKS; CORRECTING FLUIDS; WOODSTAINS; PASTES OR SOLIDS FOR COLOURING OR PRINTING; USE OF MATERIALS THEREFOR
    • C09D167/00Coating compositions based on polyesters obtained by reactions forming a carboxylic ester link in the main chain; Coating compositions based on derivatives of such polymers
    • C09D167/08Polyesters modified with higher fatty oils or their acids, or with natural resins or resin acids
    • CCHEMISTRY; METALLURGY
    • C09DYES; PAINTS; POLISHES; NATURAL RESINS; ADHESIVES; COMPOSITIONS NOT OTHERWISE PROVIDED FOR; APPLICATIONS OF MATERIALS NOT OTHERWISE PROVIDED FOR
    • C09DCOATING COMPOSITIONS, e.g. PAINTS, VARNISHES OR LACQUERS; FILLING PASTES; CHEMICAL PAINT OR INK REMOVERS; INKS; CORRECTING FLUIDS; WOODSTAINS; PASTES OR SOLIDS FOR COLOURING OR PRINTING; USE OF MATERIALS THEREFOR
    • C09D5/00Coating compositions, e.g. paints, varnishes or lacquers, characterised by their physical nature or the effects produced; Filling pastes
    • C09D5/14Paints containing biocides, e.g. fungicides, insecticides or pesticides
    • BPERFORMING OPERATIONS; TRANSPORTING
    • B27WORKING OR PRESERVING WOOD OR SIMILAR MATERIAL; NAILING OR STAPLING MACHINES IN GENERAL
    • B27KPROCESSES, APPARATUS OR SELECTION OF SUBSTANCES FOR IMPREGNATING, STAINING, DYEING, BLEACHING OF WOOD OR SIMILAR MATERIALS, OR TREATING OF WOOD OR SIMILAR MATERIALS WITH PERMEANT LIQUIDS, NOT OTHERWISE PROVIDED FOR; CHEMICAL OR PHYSICAL TREATMENT OF CORK, CANE, REED, STRAW OR SIMILAR MATERIALS
    • B27K3/00Impregnating wood, e.g. impregnation pretreatment, for example puncturing; Wood impregnation aids not directly involved in the impregnation process
    • B27K3/34Organic impregnating agents
    • B27K3/50Mixtures of different organic impregnating agents

Definitions

  • the present specification relates to storage-stable aqueous formulations which in addition to hydrolysis-sensitive active compounds comprise special binders for stabilizing the active compounds.
  • trihalogenomethylthio compounds such as dichlofluanid, tolylfluanid, fluorfolpet and folpet is based on the ability of the N—S bond to open in order subsequently to react nucleophilic groups (e.g. SH groups).
  • aqueous systems comprising at least one hydrolysis-sensitive active compound in combination with binders which consist of alkyd resins based on vegetable oils and/or acrylate dispersions and which in aqueous systems have a pH ⁇ 7.
  • Active compounds sensitive to hydrolysis are, in particular, fungicides, bactericides and insecticides which in acidic, neutral and especially alkaline systems have a half-life of a few minutes to six months.
  • Such active compounds are, in particular, compounds containing a functional group —N—S—CCl 2 X, where X preferably represents fluorine, chlorine or CHCl 2 .
  • Hydrolysis-sensitive active compounds for the purposes of the invention are, in particular, folpet, captan and captafol and, preferably, dichlofluanid, tolylfluanid and fluorfolpet.
  • Binders for the purposes of the invention are alkyd resins and acrylate dispersions, which may also, optionally, be present in copolymeric form and which have the characteristic that in aqueous solutions or emulsions they have a pH ⁇ 7, in particular ⁇ 5, preferably ⁇ 3.
  • alkyd/maleic anhydride copolymers alkyd/modified linseed oil, alkyd resins, alkyd resin/soya oil/linseed oil in combination with acrylate dispersion.
  • the aqueous systems of the invention, or ready-to-use compositions contain preferably from 0.001 to 90, in particular from 0.01 to 50, more preferably from 0.1 to 5, with particular preference from 0.1 to 2 per cent by weight of active compound and preferably from 3 to 80, in particular from 5 to 50 and, more preferably, from 5 to 30 per cent by weight of binder.
  • aqueous systems are water-based paints such as, in particular, emulsion paints and antifouling paints and also, preferably, wood preservatives such as, in particular, wood preservative varnishes and primers.
  • Aqueous systems optionally include constituents which are common for—in particular—wood preservative varnishes, emulsion paints and antifouling paints, such as pigments, dyes, auxiliaries, binders, emulsifiers, dispersants and further active compounds such as fungicides, insecticides and/or bactericides not sensitive to hydrolysis.
  • constituents which are common for—in particular—wood preservative varnishes, emulsion paints and antifouling paints such as pigments, dyes, auxiliaries, binders, emulsifiers, dispersants and further active compounds such as fungicides, insecticides and/or bactericides not sensitive to hydrolysis.
  • the aqueous systems of the invention have the advantage over the known systems that the active compounds are stable for long periods against hydrolysis and decomposition, both in an acidic and in a neutral medium.
  • Tolylfluanid (TF) is incorporated into various water-based wood preservatives with stirring. The samples are tested for their storage stability at room temperature. The amount of active compound in the samples is measured by means of HPLC.

Landscapes

  • Life Sciences & Earth Sciences (AREA)
  • Chemical & Material Sciences (AREA)
  • Engineering & Computer Science (AREA)
  • Wood Science & Technology (AREA)
  • General Health & Medical Sciences (AREA)
  • Health & Medical Sciences (AREA)
  • Plant Pathology (AREA)
  • Zoology (AREA)
  • Dentistry (AREA)
  • Pest Control & Pesticides (AREA)
  • Environmental Sciences (AREA)
  • Agronomy & Crop Science (AREA)
  • Materials Engineering (AREA)
  • Organic Chemistry (AREA)
  • Toxicology (AREA)
  • Oil, Petroleum & Natural Gas (AREA)
  • Chemical Kinetics & Catalysis (AREA)
  • Agricultural Chemicals And Associated Chemicals (AREA)
  • Compositions Of Macromolecular Compounds (AREA)
  • Paints Or Removers (AREA)

Abstract

The invention relates to storage-stable aqueous formulations containing at least one hydrolysis-sensitive active compound in combination with binders consisting of an alkyd resin based on vegetable oils and/or acrylate dispersions and having a pH≦7.

Description

  • The present specification relates to storage-stable aqueous formulations which in addition to hydrolysis-sensitive active compounds comprise special binders for stabilizing the active compounds. [0001]
  • Their sensitivity to hydrolysis imposes conditions on the suitability of many broad-spectrum fungicides for use in water-based systems. [0002]
  • The mode of action of, for example, trihalogenomethylthio compounds such as dichlofluanid, tolylfluanid, fluorfolpet and folpet is based on the ability of the N—S bond to open in order subsequently to react nucleophilic groups (e.g. SH groups). [0003]
  • The half-life of the majority of these compounds in aqueous systems is a few minutes at alkaline pH levels (about pH 9), in the neutral range (about pH 7) a few hours, and in the acidic range (about pH 4) a few days. [0004]
  • Their use in water-based, so-called ready-to-use wood preservation varnishes and primers, emulsion paints and antifouling paints is therefore not an option owing to the short shelf life, which derives from the instability of the fungicides. [0005]
  • Surprisingly and totally unexpectedly it has now been found that active compounds sensitive to hydrolysis can be stabilized by using specific binder systems. [0006]
  • The specification therefore provides aqueous systems comprising at least one hydrolysis-sensitive active compound in combination with binders which consist of alkyd resins based on vegetable oils and/or acrylate dispersions and which in aqueous systems have a pH≦7. [0007]
  • Active compounds sensitive to hydrolysis are, in particular, fungicides, bactericides and insecticides which in acidic, neutral and especially alkaline systems have a half-life of a few minutes to six months. [0008]
  • Such active compounds are, in particular, compounds containing a functional group —N—S—CCl[0009] 2X, where X preferably represents fluorine, chlorine or CHCl2.
  • Hydrolysis-sensitive active compounds for the purposes of the invention are, in particular, folpet, captan and captafol and, preferably, dichlofluanid, tolylfluanid and fluorfolpet. [0010]
  • Binders for the purposes of the invention are alkyd resins and acrylate dispersions, which may also, optionally, be present in copolymeric form and which have the characteristic that in aqueous solutions or emulsions they have a pH≦7, in particular ≦5, preferably ≦3. [0011]
  • Examples of preferred binders which may be mentioned are as follows: [0012]
  • alkyd/maleic anhydride copolymers, alkyd/modified linseed oil, alkyd resins, alkyd resin/soya oil/linseed oil in combination with acrylate dispersion. [0013]
  • Both the active compounds and the binders are known and are commercially available. [0014]
  • The aqueous systems of the invention, or ready-to-use compositions, contain preferably from 0.001 to 90, in particular from 0.01 to 50, more preferably from 0.1 to 5, with particular preference from 0.1 to 2 per cent by weight of active compound and preferably from 3 to 80, in particular from 5 to 50 and, more preferably, from 5 to 30 per cent by weight of binder. [0015]
  • Preferred examples of aqueous systems are water-based paints such as, in particular, emulsion paints and antifouling paints and also, preferably, wood preservatives such as, in particular, wood preservative varnishes and primers. [0016]
  • Aqueous systems optionally include constituents which are common for—in particular—wood preservative varnishes, emulsion paints and antifouling paints, such as pigments, dyes, auxiliaries, binders, emulsifiers, dispersants and further active compounds such as fungicides, insecticides and/or bactericides not sensitive to hydrolysis. [0017]
  • The aqueous systems of the invention have the advantage over the known systems that the active compounds are stable for long periods against hydrolysis and decomposition, both in an acidic and in a neutral medium. [0018]
  • The invention is elucidated further by the following examples. The invention is not restricted to the examples. In the text below, percentages are by weight. [0019]
  • EXAMPLE
  • Tolylfluanid (TF) is incorporated into various water-based wood preservatives with stirring. The samples are tested for their storage stability at room temperature. The amount of active compound in the samples is measured by means of HPLC. [0020]
  • The table below reports the results: [0021]
    TABLE 1
    % TF % TF, storage at RT
    Ex.- Binder pH of after 1 2 3 9 12
    No % Description B theor. prep. mth. mth. mth. mth. mth.
    1 16.5 Alkyd/soya/linseed oil + 2 0.74 0.72 0.80 0.69 0.69 0.67 0.69
    acrylate dispersion
    2 16.5 Alkyd 3.5-5 0.74 0.74 0.97 0.75 0.64 0.63 0.62

Claims (10)

1. Aqueous systems comprising at least one hydrolysis-sensitive active compound in combination with binders which consist of alkyd resin based on vegetable oils and/or acrylate dispersions and have a pH≦7.
2. Aqueous systems according to claim 1, in which the binders have a pH≦5.
3. Aqueous systems according to claim 1, in which the binders have a pH≦3.
4. Aqueous systems according to claim 1 which comprise as active compound compounds having a functional group N—S—CCl2X, where X represents halogen or optionally halogen-substituted C1-C4-alkyl.
5. Aqueous systems according to claim 1, which comprise as active compounds folpet, captan, captafol, dichlofluanid, tolylfluanid and/or fluorfolpet.
6. Use of binders which consist of alkyd resin based on vegetable oils and/or acrylate dispersions and have a pH≦7 in water for stabilizing hydrolysis-sensitive active compounds in aqueous systems.
7. Use of binders which consist of alkyd resin based on vegetable oils and/or acrylate dispersions and have a pH≦7 in water in combination with hydrolysis-sensitive active compounds for protecting aqueous systems against microbial infestation.
8. Use according to one of claims 6 and 7, characterized in that the aqueous systems have a pH≦5.
9. Binders comprising alkyd resin based on vegetable oils and/or acrylate dispersions having a pH≦7 in water in combination with hydrolysis-sensitive active compounds.
10. Method of stabilizing hydrolysis-sensitive active compounds in aqueous systems, characterized in that the aqueous systems are admixed with binders consisting of alkyd resin based on vegetable oils and/or acrylate dispersions and having a pH≦7 in water.
US09/552,044 1999-04-24 2000-04-19 Water-based formulations with fungicidal action Abandoned US20020055566A1 (en)

Applications Claiming Priority (2)

Application Number Priority Date Filing Date Title
DE19918730A DE19918730A1 (en) 1999-04-24 1999-04-24 Water-based formulations with fungicidal activity
DE19918730.4 1999-04-24

Publications (1)

Publication Number Publication Date
US20020055566A1 true US20020055566A1 (en) 2002-05-09

Family

ID=7905783

Family Applications (1)

Application Number Title Priority Date Filing Date
US09/552,044 Abandoned US20020055566A1 (en) 1999-04-24 2000-04-19 Water-based formulations with fungicidal action

Country Status (12)

Country Link
US (1) US20020055566A1 (en)
EP (1) EP1046337B1 (en)
JP (1) JP5088983B2 (en)
KR (1) KR20010014703A (en)
AT (1) ATE290780T1 (en)
CZ (1) CZ295971B6 (en)
DE (2) DE19918730A1 (en)
DK (1) DK1046337T3 (en)
EE (1) EE04512B1 (en)
HU (1) HUP0001559A3 (en)
NO (1) NO323351B1 (en)
PL (1) PL196416B1 (en)

Citations (4)

* Cited by examiner, † Cited by third party
Publication number Priority date Publication date Assignee Title
US3113399A (en) * 1961-04-05 1963-12-10 Cargill Inc Protected seed
US5248450A (en) * 1989-03-02 1993-09-28 Desowag Materialschutz Gmbh Composition for use an an agent or concentrate for the preservation of wood or wood materials
US5972971A (en) * 1993-06-21 1999-10-26 Bayer Aktiengesellschaft Fungicidal active compound combinations
US5990143A (en) * 1991-09-19 1999-11-23 Bayer Aktiengesellschaft Water-based, solvent- and emulsifier-free microbicidal active compound combination

Family Cites Families (9)

* Cited by examiner, † Cited by third party
Publication number Priority date Publication date Assignee Title
DE3004319A1 (en) * 1980-02-06 1981-08-13 Desowag-Bayer Holzschutz GmbH, 4000 Düsseldorf WOOD PROTECTIVE CONCENTRATE AND PRODUCT MADE THEREOF FOR THE PRESERVATION OF WOOD AND WOOD MATERIALS
DD153888A1 (en) * 1980-06-04 1982-02-10 Horst Kirk BIOZIDE-EQUIPPED WAESSER DISPERSION PAINTINGS
DE3414244C2 (en) * 1984-04-14 1994-02-10 Desowag Materialschutz Gmbh Wood preservative paint, preferably wood preservative paint
JPH02279602A (en) * 1989-04-19 1990-11-15 Takeda Chem Ind Ltd Termite-proofing aqueous suspension formulation
DE3927806A1 (en) * 1989-08-23 1991-04-11 Desowag Materialschutz Gmbh MEDIUM OR CONCENTRATE FOR PRESERVING WOOD OR WOOD MATERIALS
DE4209939A1 (en) * 1992-03-27 1993-09-30 Desowag Materialschutz Gmbh Emulsifier-free, water-dilutable concentrate or means for preserving wood and wood-based materials
US6017955A (en) * 1995-06-07 2000-01-25 Troy Technology Corporation, Inc. Method of stabilizing biocidal compositions of haloalkynyl compounds
JPH0977609A (en) * 1995-09-12 1997-03-25 Dainippon Ink & Chem Inc Reducing agent against chemical injury caused by herbicide and reduction of growth hindrance against lawn grass by herbicide
WO1999039886A1 (en) * 1998-02-06 1999-08-12 Lonza Ag Protective agents for wood

Patent Citations (4)

* Cited by examiner, † Cited by third party
Publication number Priority date Publication date Assignee Title
US3113399A (en) * 1961-04-05 1963-12-10 Cargill Inc Protected seed
US5248450A (en) * 1989-03-02 1993-09-28 Desowag Materialschutz Gmbh Composition for use an an agent or concentrate for the preservation of wood or wood materials
US5990143A (en) * 1991-09-19 1999-11-23 Bayer Aktiengesellschaft Water-based, solvent- and emulsifier-free microbicidal active compound combination
US5972971A (en) * 1993-06-21 1999-10-26 Bayer Aktiengesellschaft Fungicidal active compound combinations

Also Published As

Publication number Publication date
HUP0001559A2 (en) 2001-01-29
JP5088983B2 (en) 2012-12-05
DK1046337T3 (en) 2005-05-17
DE50009754D1 (en) 2005-04-21
HUP0001559A3 (en) 2002-03-28
PL339851A1 (en) 2000-11-06
EE04512B1 (en) 2005-08-15
NO20002071D0 (en) 2000-04-19
CZ295971B6 (en) 2005-12-14
EP1046337A2 (en) 2000-10-25
EE200000066A (en) 2000-12-15
HU0001559D0 (en) 2000-06-28
NO323351B1 (en) 2007-04-02
EP1046337B1 (en) 2005-03-16
PL196416B1 (en) 2007-12-31
CZ20001488A3 (en) 2000-12-13
KR20010014703A (en) 2001-02-26
NO20002071L (en) 2000-10-25
ATE290780T1 (en) 2005-04-15
EP1046337A3 (en) 2001-04-18
JP2000336006A (en) 2000-12-05
DE19918730A1 (en) 2000-10-26

Similar Documents

Publication Publication Date Title
JP5306177B2 (en) Stable aqueous suspension concentrates, compositions, coating compositions, personal care compositions, products and stable water dispersible solids
EP1225803B1 (en) Antimicrobial mixtures of 1,3-bis(hydroxymethyl)-5,5-dimethylhydantoin and 1,2-benzisothiazolin-3-one
CA2055838A1 (en) Use of halogen-containing organic stabilizers for 3-isothiazolones
US5147884A (en) Preservative for aqueous products and systems
US5874453A (en) Synergistic antimicrobial compositions containing a dimethylamide of a carboxylic acid with mixture of 2-(thiocyanomethylthio) benzothiazone and methylenebis (thiocyanate)
EP1225804B1 (en) Low-temperature-stable preservatives
US5078781A (en) Bipyridilium herbicidal compositions
US6140370A (en) Stabilized alkyd based compositions containing halopropynl compounds
WO1998033380A1 (en) Algicidal and fungicidal preservative with alternaria-activity
EP1071330B1 (en) Stabilization of isothiazolone
EP0741518A1 (en) Synergistic antimicrobial compositions containing methylene-bis(thiocyanate) and an organic acid
US20020055566A1 (en) Water-based formulations with fungicidal action
US20050065199A1 (en) Low-salt or salt-free microbicidal composition based on isothiazolone derivatives and pyrion disulphide
CA2006333A1 (en) Organic stabilizers
US4011062A (en) Novel compositions containing acetylenic glycol safeners for spring wheat

Legal Events

Date Code Title Description
AS Assignment

Owner name: BAYER AKTIENGESELLSCHAFT, GERMANY

Free format text: ASSIGNMENT OF ASSIGNORS INTEREST;ASSIGNORS:BUSCHHAUS, HANS-ULRICH;SPETMANN, PETER;JAETSCH, THOMAS;AND OTHERS;REEL/FRAME:010757/0741;SIGNING DATES FROM 20000207 TO 20000208

AS Assignment

Owner name: LANXESS DEUTSCHLAND GMBH, GERMANY

Free format text: ASSIGNMENT OF ASSIGNORS INTEREST;ASSIGNOR:BAYER AG;REEL/FRAME:018584/0319

Effective date: 20061122

STCB Information on status: application discontinuation

Free format text: ABANDONED -- FAILURE TO RESPOND TO AN OFFICE ACTION